Ensuring that the provisions on bioenergy in the recast EU Renewable Energy Directive deliver genuine climate benefits Bioenergy has a role to play in decarbonisation of the EU energy system. But the sustainability criteria for

bioenergy proposed by the European Commission in its recast of the EU Renewable Energy Directive are deeply

flawed. Stricter rules are needed to ensure that bioenergy used in the EU delivers genuine climate benefits over

the fossil alternative.

2 WWF EPO | EU Bioenergy Policy Briefing Paper | June 2017

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EU bioenergy policy has been the subject of fierce

debate for over a decade, with much of the

controversy stemming from a failure to distinguish

between whether something is sustainable in an

ecological or commercial sense and whether it is ‘low

carbon’ (i.e. delivers GHG savings over the short to

medium term, in pursuit of the 1.5°C goal).

Some types of bioenergy, for example those produced

from agricultural wastes and residues, municipal

organic waste, industry residues (e.g. from saw mills

and paper mills) and smaller forest harvest residues

such as tops and branches can be significantly lower

carbon than fossil fuels, provided the feedstocks have

no other use – meaning that they are exploited in line

with the EU waste hierarchy and the principle of

cascading use.

However it is now clear that bioenergy from purpose-

grown agricultural crops, stemwood (i.e. tree trunks)

and coarse forest harvest residues such as stumps is

unlikely to be ‘lower carbon’ than conventional fossil

fuels in the sense described above and in many cases

will be counterproductive in climate terms.

The European Commission’s proposed bioenergy

sustainability criteria, which are based on LULUCF

accounting, GHG criteria that only cover process

emissions and sustainable forest management (the

latter, incidentally, questionably interpreted), will not

exclude such feedstocks and so will not ensure that

bioenergy used in the EU delivers genuine climate

benefits.

Instead, the EU should apply GHG criteria based on a

comprehensive lifecycle assessment that includes all

relevant factors, including biogenic (i.e. combustion)

emissions, changes in above and below ground

carbon stocks, forgone sequestration, emissions from

ILUC, methane emissions from stored wood fuel and

emissions resulting from any displacement effects.

Given the urgency of tackling climate change and the

ambition of the Paris Agreement the assessment

should involve a climate-relevant timeframe, for

example the next 10-20 years.

In the absence of such an approach the EU should

exclude from eligibility for subsidies or other policy

incentives those types of bioenergy that are unlikely

in most circumstances to comply with such GHG

requirements. This means:

1. Phasing out subsidies and incentives for

purpose-grown biofuel crops, which are

unlikely to be a good use of land from a climate

perspective. For pragmatic reasons WWF accepts

that this could be done gradually, for example in

line with the Commission’s proposal of an initial

reduction in the cap on food-based biofuels from

7.0% to 3.8%;

2. Phasing out subsidies and incentives for the use

of stemwood and stumps. Less coarse harvest

residues such as tops and branches should

remain eligible for these but only if used in

installations employing high efficiency co-

generation (i.e. combined heat and power).

3. Ensuring that wastes and residues only

benefit from subsidies or incentives if they have

no significant alternative uses, whether for food,

animal feed or bio-based materials (the cascading

use principle). This means for example removing

molasses and tall oil from the list of ‘advanced’

biofuel feedstocks in Annex IX of the Renewable

Energy Directive.

In addition to the above, the EU should set strict

efficiency requirements – and apply these and the

other sustainability criteria to all users of biomass

fuels over 1MW in size. The proposed 20MW

threshold is far too high and risks creating perverse

incentives to build medium-sized plant.

Genuinely low carbon bioenergy from wastes and

residues will remain a rare commodity in the EU

relative to total energy demand. Bioenergy is

therefore unlikely to be a major factor in the

decarbonisation agenda or in overall EU energy

security, and the majority of EU energy supply in

2050 will need to come from sources such as wind

and solar.

The EU heat and transport sectors will for the most

part need to be electrified, or supplied through

synthetic low carbon fuels produced from renewable

electricity, for example hydrogen or, possibly, fuels

made by combining that with CO2 from direct air

capture. Research and development of such options,

which need not compete for land with food

production or carbon sequestration, should be a high

priority.

The fact that certain types of bioenergy are high

carbon should not be construed as an argument in

favour of fossil fuels. On the contrary, it is an

argument for energy efficiency, changes in lifestyles

and consumption, the rapid deployment of low

carbon technologies such as wind and solar and

investment in the new options described above.

The EU agriculture and forestry sectors have a critical

role to play in relation to climate change. But it is in

the efficient and sustainable production of food and

timber and the storing of carbon in landscapes. Not,

primarily, in providing material to burn.

4 WWF EPO | EU Bioenergy Policy Briefing Paper | June 2017

Late last year the European Commission published

its proposals for a recast Renewable Energy

Directive, part of a package of legislation aimed at

ensuring ‘clean energy for all Europeans’1. In

addition to covering issues such as national support

schemes and community energy projects the

proposal set out detailed criteria on the

sustainability of bioenergy, meaning biofuels,

bioliquids and solid and gaseous biomass fuels.

The draft legislation is now under negotiation in the

European Parliament and Council and has already

provoked strong reactions from stakeholders. This

is nothing new: EU bioenergy policy has been the

subject of fierce controversy for over a decade, with

decision makers bombarded on all sides by

competing claims2 and left with the impression that

the subject is impenetrably complex.

Much of the confusion in the debate stems from a

failure to distinguish between whether something is

sustainable in an ecological or commercial sense

and whether it is ‘low carbon’, meaning that it

delivers GHG savings over the short to medium

term. Something can be sustainable in the former

sense and yet be counterproductive as a means of

tackling climate change in the next ten to twenty

years. Examples would include the use of

agricultural land for purpose grown biofuel crops

and the harvesting of stemwood (i.e. whole trees)

for heat and power – something that is happening

on an increasingly large scale3.

1 https://ec.europa.eu/energy/en/news/commission-proposes-new-

rules-consumer-centred-clean-energy-transition 2 For recent examples relating to Finnish and UK policy see the

following letters and references therein: http://www.bios.fi/publicstatement/publicstatement240317.pdf, https://www.chathamhouse.org/sites/files/chathamhouse/publications/2017-04-05-ResponsetoIEABioenergy.pdf, http://www.eubioenergy.com/wp-content/uploads/2015/03/Response-to-IEA-critique-of-CH-report_final.pdf and http://www.pfpi.net/wp-content/uploads/2017/03/Scientists-bioenergy-letter-March-15-2017.pdf. 3 Over 5 million hectares in the EU are currently devoted to biofuel

crops (https://ec.europa.eu/agriculture/markets-and-prices/medium-term-outlook_en). On the forestry side a 2016 report for the European Commission noted that “current EU imports [of bioenergy] from the southeast [US are] dominated by wood pellets based on dedicated pulpwood (about 60- 75%, mostly softwood pulpwood, but also hardwood pulpwood…)” (http://bookshop.europa.eu/en/environmental-implications-of-increased-reliance-of-the-eu-on-biomass-from-the-south-east-us-pbKH0116687/). The same report notes that “…according to the National Renewable Energy Action Plans, biomass used for heating, cooling and electricity would supply about 42% of the 20% renewable energy target for 2020. If this is to be achieved and the present renewables mix stays in place, the amount of biomass used for energy purposes in the EU would be equivalent to today's total wood harvest in the EU. It is therefore highly likely that EU will have to import increasing amounts of biomass and thus increase the pressure on global forest resources”. For information on the impacts outside the EU see for example the extensive evidence

This briefing paper summarises the evidence on the

impacts of various types of EU bioenergy use,

focusing on the climate aspects4. It then assesses the

policy proposals put forward by the European

Commission and considers what changes to those

may be necessary to ensure that bioenergy used in

the EU is genuinely sustainable from an ecological,

social and climate perspective. It does not attempt

to cover the entire global biomass sector (much of

which consists of traditional subsistence fuelwood

in developing countries), and is without prejudice to

whatever bioenergy policies may be appropriate in

third countries. Instead it considers the specific

question of what types of bioenergy should actively

be incentivised, for example through subsidies,

blending mandates or other policy incentives

permitted under EU law.

The broader context

Before considering the European Commission’s

recent proposals on the subject, it is important to

examine the broader context. EU bioenergy policy

does not operate in a vacuum, and is intimately

connected with a range of other economic, social

and environmental issues. In many cases these have

changed in recent years, and justify a fresh

approach: Examples include:

Accelerating climate change. 2016 was the

warmest year since reliable record-keeping

began, in the nineteenth century, and average

global temperature is already close to the target

of 1.5°C above pre-industrial levels that was

included in the Paris Agreement. Very rapid

emissions reduction in all sectors is now

essential – with what happens in the next 10 or

20 years being particularly critical.

The need for ‘negative emissions’ as soon

as possible. Few plausible scenarios exist for

meeting the targets agreed in Paris that do not

involve significant ‘negative emissions’ (i.e.

increased carbon sequestration, in addition to

rapid emissions reduction). Pending the

deployment at scale of technologies such as

bioenergy with carbon capture and storage

amassed by US NGOs (e.g. https://www.dogwoodalliance.org/wp-content/uploads/2017/05/NRDC_2014-2017Booklet_DigitalVersion-resize.pdf). 4 EU bioenergy policies should also take full account of broader

socio-economic and environmental impacts, but must at a minimum ensure that bioenergy delivers carbon benefits over fossil fuels.

(BECCS) – itself the subject of various

concerns5 – one of the few cheap and practical

approaches available is to accelerate

reforestation and forest restoration6. The EU

should therefore be arguing for – and

pioneering – a massive programme of such

activities, alongside emissions reduction. This

should start immediately and be carried out in a

socially and ecologically responsible way.

Ongoing high rates of deforestation and

forest fragmentation. Far from forest cover

increasing, over a hectare of tropical rainforest

is currently either destroyed or significantly

degraded every second7, and since the mid-

1960s more than half of the world’s tropical

rainforest has been lost8. Deforestation and

forest degradation may account for anything up

to 20% of global GHG emissions9, and experts

estimate that 80% of global deforestation is due

to agriculture10.

Growing demand for food and fibre. With

one report from WRI predicting this will rise by

70-80% by 205011, pressure on land resources

(and hence forests) seems likely to increase

significantly, even with optimistic assumptions

on future agricultural yields (and the extent to

which those remain unaffected by climate

change).

The scale of energy demand. The same WRI

report, using OECD figures, estimates that it

would take all of the world’s harvested biomass

– including all crops, all wood and all biomass

grazed by livestock – to meet just 20% of global

energy demand in 205012. Given that we will

5 https://www.sei-

international.org/mediamanager/documents/Publications/Climate/SEI-WP-2016-08-Negative-emissions.pdf 6 Restoration of other high carbon habitats such as wetlands also

has potential. 7 http://www.scientificamerican.com/article/earth-talks-daily-

destruction/ 8 Global Canopy Programme (2015): Achieving Zero (Net)

Deforestation: What it means and how to get there (http://forest500.org/sites/default/files/achievingzeronetdeforestation.pdf) 9 See

http://www.europarl.europa.eu/RegData/etudes/BRIE/2015/568329/EPRS_BRI(2015)568329_EN.pdf and https://ec.europa.eu/jrc/en/science-update/reporting-greenhouse-gas-emissions-deforestation-and-forest-degradation-pan-tropical-biomass-maps 10

Wageningen University and Research Centre. "Agriculture is the direct driver for worldwide deforestation." ScienceDaily. ScienceDaily, 25 September 2012. www.sciencedaily.com/releases/2012/09/120925091608.htm 11

Searchinger and Heimlich, 2015, World Resources Institute (http://www.wri.org/publication/avoiding-bioenergy-competition-food-crops-and-land) 12

Based on an OECD baseline estimate of energy demand and on all harvested biomass currently delivering just over 200EJ/year, although action on energy efficiency would improve the situation somewhat. A different paper (http://www.sciencedirect.com/science/article/pii/S1364032114000677) notes that “All harvested biomass used for food, fodder, fibre and forest products, when expressed in equivalent heat content, equals 219 EJ/year” and compares that to current world primary

still need food and fibre, and barring a massive

increase in algae farming, sustainable bioenergy

is therefore unlikely to be a major factor in the

decarbonisation agenda or in overall energy

security. The situation in the EU is likely to be

similar, with genuinely low carbon bioenergy

from wastes and residues making at most a

modest contribution to total energy supply13

Dramatic falls in the cost of wind and

solar. In many parts of the EU wind and solar

are now competitive with new fossil plant

(although still face barriers to deployment due

to weak carbon prices, fossil fuel subsidies and

the volume of fully depreciated old coal plant on

the system).

Taken together, the above factors argue for the EU

to take a more cautious approach to bioenergy

policy than hitherto, particularly as regards types of

feedstocks that will not deliver near-term climate

benefits or that compete for land with food

production or carbon sequestration. Caution is also

necessary because there are very big differences

between types of bioenergy when it comes to their

environmental impacts.

Bioenergy from agricultural crops

One of the simplest examples of EU bioenergy use is

the production of what are sometimes called

‘conventional’ or ‘first generation’ biofuels – for

example biodiesel made from oilseed crops such as

rape, or ethanol and methane made from starch rich

crops such as maize. Such fuels can be used in place

of fossil sources and so can result in reduced

emissions of fossil CO2 to the atmosphere.

However the use of land for purpose-grown biofuel

crops comes with an opportunity cost, in that it

reduces the amount of land available for other

activities, including carbon sequestration. And as

numerous studies make clear, reforestation will

typically sequester many times more carbon from

the atmosphere per hectare (both above and below

ground) than could be saved in emissions by using

the same area of land for biofuel production. The

same will often be true of simply letting land revert

energy supply of about 550 EJ/year. An IEA estimate suggested that replacing 10% of petrol and diesel with biofuels by 2020 would require 43% and 38% of cropland area in the United States and Europe respectively (http://www.cti2000.it/Bionett/All-2004-004%20IEA%20biofuels%20report.pdf). 13

The potential for bioenergy from wastes and residues is discussed further in the report “Wasted” (https://europeanclimate.org/new-report-wasted-1-5-biofuels-made-from-waste-and-residues-could-produce-several-hundred-thousand-jobs-across-europe/). See also http://www.nature.com/nclimate/journal/v4/n2/full/nclimate2097.html for a review of estimates of biomass from wastes and residues.

to forest, grassland or other vegetation through

natural succession14.

This argument – based on ‘forgone sequestration’ –

applies regardless of whether the crop in question is

a food crop, an energy crop or a dedicated forest

plantation. Even the very fastest growing energy

crops such as sugarcane are unlikely to offer carbon

benefits compared to returning land to a high

carbon natural habitat such as forest.

For the same reason, the conversion of forest,

wetland, peatland or grassland to cropland will

typically lead to significant carbon losses, both

above and below ground, and therefore where there

is agricultural land that cannot or will not be

abandoned to reforestation the best use of that land

from a climate perspective is likely to be food or

feed production. Devoting it to purpose-grown

biofuel crops will on aggregate reduce the amount of

land available for food or feed production globally

and so increase pressures on deforestation (the

problem of indirect land use change, or ILUC15).

For both these reasons, and given the growing

demands on land described above, any large scale

diversion of agricultural land to purpose-grown

biofuel crops is likely to be sub-optimal from a

climate perspective, and a poor use of subsidies

justified on climate grounds16. This is before

considering other important issues such as local

climate regulation, flood prevention, desertification

and biodiversity – issues that (in the case of land

not needed for food production) would typically also

argue for subsidies to be targeted at reforestation,

14

E.g. see Righelato & Spracklen, 2007 “Carbon mitigation by biofuels or by saving and restoring forests” (http://user.iiasa.ac.at/~gruebler/Lectures/skku_2009/readings/righelato_biofuels_afforestation_comp_science2007.pdf) or Evans, Ramage, DiRocco and Potts, 2015 “Greenhouse Gas Mitigation on Marginal Land: A Quantitative Review of the Relative Benefits of Forest Recovery versus Biofuel Production” (http://pubs.acs.org/doi/pdfplus/10.1021/es502374f). Note that in the latter paper the high rates for miscanthus are unlikely to be realistic as they assume yields roughly three times higher than those currently being achieved in the EU (e.g. see Searle and Malins, 2014 (http://www.sciencedirect.com/science/article/pii/S0961953414000026)). Note also that only above ground biomass was considered, and so the true figures are likely to be even more supportive of carbon sequestration over biofuel production. 15

For clarity, we distinguish in this paper between ILUC and forgone sequestration, although in some studies the former is taken to include the latter. 16

Models that suggest that certain types of conventional biofuels such as maize-based ethanol deliver significant climate benefits over fossil fuels typically reach such conclusions only because they assume that there are large areas of completely unused land available that could not be reforested or support any significant natural vegetation but that can nevertheless produce high yields of bioenergy feedstock, or that there is no opportunity cost to the use of agricultural land (or residues such as starch that have other uses) for biofuel production despite agriculture being responsible for most of the deforestation that takes place globally (see earlier references).

or allowing land to revert to natural, high carbon

ecosystems.

This is not to say that the agricultural sector has no

role to play in clean energy provision. Some types of

bioenergy derived from agricultural wastes and

residues are clearly positive from a climate

perspective and should be encouraged – provided

that the feedstocks have no other use and their

extraction does not negatively affect soil fertility or

carbon content. For example, producing biogas

from the anaerobic digestion of short-lived wastes

and residues such as slurry can be very ‘low carbon’

– not least because doing so can reduce emissions of

the potent greenhouse gas methane.

Forest-based bioenergy

Another potential form of bioenergy is the use of

wood from standing (i.e. existing) forests. But it is

increasingly clear from academic research that the

dedicated harvesting of trees for energy purposes is

not only not carbon neutral but can in fact be highly

carbon intensive17. Indeed over the sort of

timescales that matter for climate change targets

and policies, namely between now and 205018, such

an approach is likely to be counterproductive as a

means of reducing emissions.

For example a critical review of the scientific

literature by Joint Research Centre (JRC) of the

European Commission19 concluded that “…the use

of stemwood from dedicated harvest for bioenergy

would cause an actual increase in GHG emissions

compared to those from fossil fuels in the short-and

medium term (decades), while it may start to

generate GHG savings only in the long-term

(several decades to centuries), provided that the

initial assumptions remain valid”. Similar

conclusions were reached by the European

Academies Science Advisory Council, which in a

recent report stated that “Increasing the carbon

storage in existing forests is a cost-effective measure

to decrease net carbon emissions, but EU policies

17

For example see Holtsmark, 2013 (http://onlinelibrary.wiley.com/doi/10.1111/gcbb.12110/full) and other references therein. See also the main text and conclusions sections of the report for DG Energy by Matthews, R. et al (2014) “Review of literature on biogenic carbon and life cycle assessment of forest bioenergy” (https://ec.europa.eu/energy/sites/ener/files/2014_biomass_forest_research_report_.pdf) and the summary of that and other studies in Annexes 7 and 8 of the European Commission bioenergy impact assessment (https://ec.europa.eu/energy/sites/ener/files/documents/1_en_impact_assessment_part4_v4_418.pdf). 18

On current trends we are likely to breach the 1.5°C target well before then (https://www.ipcc.ch/publications_and_data/ar4/wg1/en/spmsspm-projections-of.html). 19

http://publications.jrc.ec.europa.eu/repository/bitstream/JRC70663/eur25354en_online.pdf

are currently biased towards the use of forest

biomass for energy with potential negative effects

on the climate over the short to medium term”20.

The reason that dedicated harvesting of forest

biomass is counterproductive as a means of climate

change mitigation is partly this ‘carbon debt’ issue,

meaning that it can take a very long time for the

carbon released when forests are harvested for

bioenergy to be recaptured by new growth, and that

during that time there will be a climate impact

through radiative forcing. But this is compounded

by a number of other factors, namely:

The fact that emissions of CO2 and methane per

unit of energy are higher when burning wood

than when burning conventional fossil fuels

such as coal and gas21;

The fact that there will be an additional release

of carbon from stumps, roots, other residues

and soil that would not have occurred had the

trees not been cut down for energy purposes at

that point in time22;

The fact that the trees would have carried on

sequestering carbon – something that will now

not happen, or will happen at a lower rate for a

significant period23; and

The fact that there can be significant emissions

of methane from wood pellets or wood chips

while they are in storage24.

This means that something that might well be

sustainable in an ecological or commercial sense,

and would be low carbon over a suitably long time

period, will be counterproductive as a means of

addressing climate change in the next ten or twenty

years. Arguments against this conclusion based on

the fact that carbon stocks in EU forests can at the

landscape level be held constant – or even increase

– despite a certain level of harvesting for bioenergy

purposes are irrelevant, as are arguments based on

20

http://www.easac.eu/fileadmin/PDF_s/reports_statements/Forests/EASAC_Forests_web_complete.pdf 21

Intergovernmental Panel on Climate Change (2006), Guidelines for National Greenhouse Gas Inventories, Vol. 2 (Energy), Table 2.2, pages 2.16–2.17 (http://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/2_Volume2/V2_2_Ch2_Stationary_Combustion.pdf). 22

There will also be emissions associated with production and transport of bioenergy, although this is also true of fossil fuels. 23

In commercial forestry, trees are generally harvested before they reach full maturity, and the trees that replace them, if indeed the forest is replanted, are initially very small, and so sequester carbon slowly. While the rate of carbon sequestration in the forest as a whole slows down as the forest matures, at the level of a tree the rate of sequestration increases with age: bigger trees sequester more carbon than smaller trees. 24

Mirjam Röder, Carly Whittaker and Patricia Thornley, ‘How certain are greenhouse gas reductions from bioenergy? Life cycle assessment and uncertainty analysis of wood pellet-to-electricity supply chains from forest residues’, Biomass and Bioenergy 79, 2015.

the fact that forests sequester carbon at

progressively slower rates as they mature.

However it is certainly true that in many if not most

cases forests are not harvested solely for bioenergy

purposes. And where that is the case there will

inevitably be wastes and residues produced

alongside the main product or products.

Those produced in saw mills and paper mills

(sawdust, black liquor etc.) should in principle be an

acceptable feedstock for bioenergy purposes

provided they are not being used by other industries

such as the wood panel, chemical or clothing

industries – industries that could result in higher

economic benefits and/or the carbon contained in

the feedstocks being ‘locked up’ for longer in wood-

based products (i.e. the principle of cascading

use’25).

The ‘grey area’ in carbon (and other) terms is the

use for bioenergy of forest harvest residues, which

depending on who is classifying them can include

anything from twigs and leaves to stumps, tops and

branches – or even stemwood (i.e. tree trunks) that

were not suitable for timber or other products. For

such feedstocks the key question from a climate

perspective is how long, post harvesting, the carbon

they contain would have remained in the forest

before returning to the atmosphere26.

For coarser residues such as stemwood and stumps,

decay can take many years and the carbon ‘half-life’

can be considerable. Even residues that are less

coarse such as tops and branches can under certain

circumstances take decades to rot down

completely27, although a large part of the carbon

within them may have been released within 10-20

years. This issue was reviewed by the European

Commission JRC review mentioned above, which

looked at a range of different harvest residues and

end uses and concluded that the use of harvest

residues for energy would offer no benefits over

fossil fuels over a 10-year timeframe and only

modest benefits over a 50-year one (meaning they

would still not be ‘carbon neutral’ at that point).

Other reasons for caution when it comes to the use

25

See http://bookshop.europa.eu/en/cascades-pbET0416305/, http://www.wwf.eu/?263091/Cascading-use-of-wood-products-report and the EU Waste Framework Directive (2008/98/EC). 26

The use of alternative counterfactuals – for example that the materials in question would otherwise have been burnt at the roadside or removed for forest fire prevention purposes – could of course be used to justify their use for bioenergy, but may not reflect common practice before the advent of EU bioenergy subsidies, would be near-impossible to police effectively and/or is something that would be best addressed at the local level, separately from EU-wide climate policies. 27

https://aaltodoc.aalto.fi/bitstream/handle/123456789/15923/isbn9789526061887.pdf?sequence=1&isAllowed=y

of forest harvest residues for energy purposes

include that (i) the extraction of residues may

increase the need for artificial fertilisers and/or

may reduce the rate of growth in the replanted

forest – and hence the rate at which carbon is

recaptured from the atmosphere28; (ii) it may be

difficult to police exactly which residues are

removed from a forest, where they are taken and for

what purpose29; and (iii) that extraction of dead

wood can have major impacts on biodiversity (and

with it the resilience of forests).

Many of these issues are best addressed nationally

or locally, through policies on sustainable forest

management, but taken together, and in light of the

increasing urgency of reducing emissions, they

suggest that only the use of shorter-lived forest

harvest residues should actively be encouraged by

EU level climate policies, and even then only in

highly efficient applications that offer significant

near-term carbon benefits over fossils fuels. This

would be in line with the opinion of the European

Environment Agency Scientific Committee on

Greenhouse Gas Accounting in Relation to

Bioenergy30, which states that:

“It is widely assumed that biomass combustion

would be inherently ‘carbon neutral’ because it

only releases carbon taken from the atmosphere

during plant growth. However, this assumption is

not correct and results in a form of double-

counting, as it ignores the fact that using land to

produce plants for energy typically means that this

land is not producing plants for other purposes,

including carbon otherwise sequestered. If

bioenergy production replaces forests, reduces

forest stocks or reduces forest growth, which would

otherwise sequester more carbon, it can increase

the atmospheric carbon concentration. If bioenergy

crops displace food crops, this may lead to more

hunger if crops are not replaced and lead to

emissions from land-use change if they are. To

reduce carbon in the air without sacrificing other

human needs, bioenergy production must increase

the total amount of plant growth, making more

plants available for energy use while preserving

other benefits, or it must be derived from biomass

28

See, for example, Buchholz, T. et al. (2014), ‘Mineral soil carbon fluxes in forests and implications for carbon balance assessments’, GCB Bioenergy, 6:4, DOI: 10.1111/gcbb.12044; Achat, D. L. et al (2015), ‘Quantifying consequences of removing harvesting residues on forest soils and tree growth – A meta-analysis’, Forest Ecology and Management, 348 (http://dx.doi.org/10.1016/j.foreco.2015.03.042) or Achat, D. L. et al (2015), ‘Forest soil carbon is threatened by intensive biomass harvesting’, Nature Scientific Reports, 5, DOI:10.1038/srep15991 (https://www.nature.com/articles/srep15991). 29

http://www.pfpi.net/wp-content/uploads/2016/03/Report-to-SEC-on-Enviva-March-14-2016.pdf 30

The www.eea.europa.eu/ds_resolveuid/FT87KIBQX1

wastes that would decompose and neither be used

by people nor contribute to carbon sequestration.”

Other sources of bioenergy

In addition to feedstocks arising directly from

agriculture or forest-based industries there are a

number of other sources of bioenergy that are of

potential value in a bioenergy context. Municipal or

industrial organic waste, for example, if treated

separately from other waste streams, may well be a

low carbon feedstock for bioenergy production, for

example through anaerobic digestion or

combustion.

However the best option from a climate perspective

will in general be to encourage the shift to a circular

economy and reduce the extent to which waste

arises in the first place, rather than to subsidise the

combustion of waste for energy. Care should

therefore be taken to ensure that any policies in this

are consistent with the EU waste hierarchy and with

circular economy principles, and do not reduce

incentives to recycle or affect food or feed security31.

European Commission proposals

Under the Commission’s proposals, the EU’s

approach to bioenergy sustainability in the recast

Renewable Energy Directive would rest on three

main pillars:

a. A requirement that bioenergy deliver a certain

level of GHG savings relative to fossil fuels;

b. A requirement that forest bioenergy come from

forests that are ‘sustainably managed’; and

c. A requirement that forest bioenergy come from

countries or areas subject to some form of

LULUCF accounting.

The first requirement, on GHG performance, only

covers emissions from processing and transporting

the material. It does not therefore take into account

the majority of the relevant factors, namely forgone

sequestration, emissions from ILUC, changes in

above and below ground carbon stocks, methane

emissions from stored wood fuel or – perhaps most

31

See https://www.zerowasteeurope.eu/downloads/the-potential-contribution-of-waste-management-to-a-low-carbon-economy/

importantly – the emissions from actually burning

the biomass in the first place (‘biogenic emissions’).

Indeed it is because the GHG criteria in the RED are

inadequate that the EU has been forced in recent

years to introduce a 7% cap on certain types of

potentially high carbon feedstocks (although the cap

in question does not include feedstocks used for

biogas).

The second requirement, on sustainable forest

management, is for the reasons described above not

particularly relevant to the question of whether any

specific bioenergy feedstock is lower carbon than

fossil fuels. Sustainable forest management is

extremely important for other reasons, but is not a

solution to the bioenergy issue and the EU

Renewable Energy Directive is not the appropriate

vehicle for policy on that subject. WWF would also

not support the questionable interpretation of

sustainable forest management included in the

Commission proposals.

The third requirement, related to LULUCF

accounting, will not ensure that bioenergy used in

the EU is lower carbon than fossil fuels. The reasons

for this are explained in detail in the annex, but

essentially relate to the fact that the Commission’s

proposed rules on LULUCF are not rigorous enough

to ensure that all relevant emissions are counted,

either in the EU or elsewhere, and do not provide

sufficiently strong incentives to prevent the

harvesting of types of bioenergy feedstock that

would be counterproductive from a climate

perspective. It should also be noted that Member

States such as Finland are lobbying hard for the

Commission proposals to be weakened, in order

that they be able to increase harvesting of forests for

bioenergy and other purposes without having to

record that fact in their accounts.

For the reasons described above, the European

Commission’s proposals on bioenergy sustainability

are inadequate and risk leading to a further

expansion in the use of types of bioenergy that offer

no carbon benefits over fossil fuels. This would not

only be counterproductive from an emissions

perspective but also risks undermining investment

in things that offer a longer term solution, meaning

wind, solar, electrification and storage.

WWF policy recommendations

The EU needs to ensure that any growth in

bioenergy use after 2020 delivers genuine carbon

benefits over a timeframe that reflects the growing

urgency of tackling climate change and the need to

meet temperature goals set in the Paris Agreement.

On that basis WWF believes that the GHG criteria in

the Renewable Energy Directive, which require that

bioenergy deliver a certain level of saving over fossil

fuels, should be based on a comprehensive lifecycle

assessment that includes not just process and

transport emissions but also (as appropriate)

biogenic emissions, changes in above and below

ground carbon stocks, forgone sequestration,

emissions from ILUC, methane emissions from

stored wood fuel, emissions resulting from any

displacement effects (for example the diversion of

feedstocks in use by other industries) and any other

relevant factors – for example the impact on

regrowth rates of reduced soil fertility. The

methodology used for the assessment, including the

issue of system boundaries, must be standardised

and credible. Given the urgency of tackling climate

change the criteria should also require that the

required saving be delivered within a climate-

relevant timeframe, for example the next 10-20

years.

In the absence of such an approach the EU should

exclude from eligibility for subsidies or other policy

incentives32 the use of those types of bioenergy that

would be unlikely in most circumstances to comply

with such GHG requirements. This means:

1. Phasing out subsidies and incentives for

purpose-grown biofuel crops, which are

unlikely to be a good use of land from a climate

perspective. For pragmatic reasons WWF

accepts that this could be done gradually, for

example in line with the Commission’s proposal

of an initial reduction in the cap from 7.0% to

3.8%;

2. Phasing out subsidies and incentives for the use

of stemwood and stumps. Less coarse

residues such as tops and branches should be

eligible for support but only if used in

installations employing high efficiency co-

generation (i.e. combined heat and power)33.

3. Ensuring that wastes and residues only

benefit from incentives or subsidies if they have

no significant alternative uses for food, animal

feed or bio-based materials (the cascading use

principle). This means for example removing

molasses and tall oil from the list of ‘advanced’

biofuel feedstocks in Annex IX.

32

For example blending mandates for fuel providers, tax incentives etc. 33

This is without prejudice to any rules on sustainable forest management that may be applied at national or local level, for example requirements under certification schemes to leave smaller residues in the forest to maintain soil fertility and support biodiversity. The EU should monitor extraction of tops and branches in order to assess risks to sustainability. If such risks are identified, the EU should consider excluding tops and branches from eligibility for subsidies or incentives.

Such an approach would have the benefit of being

relatively easy to apply and enforce and should in

principle ensure that all bioenergy used in the EU

were significantly lower carbon than conventional

fossil fuels. It would build on the approach taken for

advanced biofuels, where only certain feedstocks are

deemed to be eligible, and would be consistent with

the best available scientific advice.

There are a number of other changes that should be

made to the Commission proposals, as follows:

Co-firing of biomass risks undermining the

phasing out of coal and so should not be eligible

for subsidies or other incentives

Minimum efficiency standards should apply

to all installations using biomass fuels over a

certain size, for example 85% conversion

efficiency for residential or commercial

installations and 70% for industrial

applications. And the minimum threshold for

this and for other sustainability criteria should

be 1 MW, with no exceptions for security of

supply. The proposed 20MW threshold is too

high and risks creating perverse incentives to

build medium-sized plant.

The existing rules on sourcing of biofuel

feedstocks from areas of high biodiversity

should be extended to forest biomass.

The possibility for MS to impose stricter

sustainability criteria is welcome but should

be extended to biofuels and bioliquids as well as

biomass fuels.

Similarly, the review clause proposed by the

Commission is positive but should be backed up

by effective monitoring and should apply

equally to the rules on biofuels and bioliquids.

Having reformed its own bioenergy policy regime,

the EU should press for similar rules to be applied

internationally. If the rest of the world were to

adopt the EU’s current or proposed future approach

– for example if China were to shift from burning

coal to burning wood from Russian forests – the

impact on the climate and on natural ecosystems

could be extremely damaging

Alternatives to bioenergy

Bioenergy has until recently been seen as an

important means of decarbonising sectors such as

heat and transport. But by definition, heat and

transport cannot be decarbonised through the use

of types of bioenergy that are higher carbon than

the fossil fuels they replace. And as this paper

makes clear, the volumes of genuinely low carbon

bioenergy are unlikely to be significant compared to

global energy demand (see ‘context’ section above).

The use of bioenergy in certain sectors (for example

power generation, space and water heating, cars and

vans) should therefore not be encouraged, in light of

risks that it could lead to investment in assets that

will later become stranded, and delay the transition

to wind and solar (and electrification) that needs to

happen in those sectors. Indeed the vast majority of

EU transport energy and heat demand will in future

need to be met (directly or indirectly) through

sources such as wind and solar. Technologies for

doing this are in some cases and/or places already

available, for example electric vehicles supplied

from the grid and district heating systems with

storage supplied from low carbon sources such as

large scale marine heat pumps.

However other alternatives to bioenergy will also be

needed if the EU is to meet its commitments under

the Paris Agreement – for example to decarbonise

certain forms of transport such as aviation and

shipping and various high temperature industrial

processes. One option in this context may be an

increase in the use of hydrogen produced from

renewable electricity and water (i.e. ‘power to gas’).

Or, possibly, if this is combined with direct air

capture of CO2, the production of energy-dense

liquid fuels (power to liquids). The use of solar or

wind power to create synthetic fuels is likely to be a

far more efficient use of land than biofuel

production from purpose-grown crops34 and can

occur alongside other productive uses of land or on

arid land that has no value for food production or

carbon sequestration.

However such technologies – and in particular

direct air capture of CO2 – are currently very

expensive and therefore, as with wind and solar in

34

A study by Germany’s main environmental protection agency published in September last year found that e-fuel production using wind or solar power delivered far higher GHG savings per hectare than biofuels: https://www.umweltbundesamt.de/en/publikationen/power-to-liquids-potentials-perspectives-for-the

the past, considerable further global investment in

research and development is required to bring down

costs and/or develop alternatives35.

Jobs and growth in rural areas and the role of agriculture and forestry in climate change mitigation

The need to avoid high carbon types of bioenergy

doesn’t mean that all EU land and forests should be

untouched nature reserves. As noted above, global

demand for food and fibre is expected to increase

dramatically over the coming decades and there will

be major opportunities for those working in the

rural economy in future the without an expansion in

bioenergy production.

Forestry, for example, is a key economic sector in

many Member States, and there is scope for ongoing

use of the EU’s ‘working forests’ provided that that

is done sustainably. In addition, the use of wood in

long-lived products or in buildings may in some

circumstances deliver GHG benefits, if it replaces

carbon intensive materials such as steel and

concrete and if a high proportion of the harvested

wood is used for that purpose. A largely wooden

building was recently completed for the University

of British Columbia that reaches to over fifty metres

high, and use of Cross-Laminated Timber (CLT) in

construction is an increasingly common practice36.

Similarly there are huge potential climate benefits

from the wider use of agricultural techniques that

increase the carbon content of soils, and from the

restoration of grasslands, forest and other natural,

high carbon ecosystems. Payments under the

Common Agricultural Policy, which still absorbs

close to 40% of the entire EU budget, could be

reoriented to reward such activities by farmers and

land managers, rather than, as they do at present,

rewarding farmers for keeping farmland clear of

vegetation. Such a reorientation could also be done

in such a way as to greatly boost employment in the

agriculture sector, for example by ending the

disproportionate transfer of funds to large,

mechanised farms and by taking all dimensions of

sustainability into account in the design of policy

schemes.

35

For a relatively positive assessment of potential future costs see: https://www.researchgate.net/publication/313842230_Long-Term_Hydrocarbon_Trade_Options_for_the_Maghreb_Region_and_Europe-Renewable_Energy_Based_Synthetic_Fuels_for_a_Net_Zero_Emissions_World. Other papers (e.g. http://www.sciencedirect.com/science/article/pii/S1876610211003900) suggest direct air capture of CO2 could be prohibitively expensive. Further research is needed in this area. 36

https://www.sciencedaily.com/releases/2016/09/160930145847.htm. See also http://waughthistleton.com/dalston-lane/

12 WWF EPO | EU Bioenergy Policy Briefing Paper | June 2017

LULUCF accounting and bioenergy Under current EU and international rules, emissions from biomass are considered to be zero at the point of

combustion – on the assumption that all of the associated emissions (in the Land Use, Land Use Change and

Forestry (LULUCF) sectors) will have been properly accounted for when the forest or crop was harvested (and/or

that all carbon released into the atmosphere will be recaptured through subsequent growth).

But even in the EU, which has worked hard to develop an effective LULUCF regime and can rightly be considered

a world leader in the field, the carbon accounting in the LULUCF sector is inadequate. This is partly because

calculating changes in landscape carbon stocks is complex and involves a certain level of uncertainty, but also

because of the idiosyncratic way in which accounting is carried out in certain LULUCF sectors in the EU. In the

forest management sector, for example, instead of carbon stocks being compared with a fixed historical level (as

is the case for all other emissions sectors), they are compared with a projected future ‘forest reference level’

determined by the relevant Member State. Member States have in many cases set forest reference levels that bear

little relation to historical harvesting levels (for example see figure 1, below) and so large volumes of wood can be

harvested without it ever showing up as a debit in the country’s carbon accounts.

Figure 1: The EU forest reference level in blue, which is based on levels set by Member States

following introduction of the EU Renewable Energy Directive in 2009, bears little relation to

actual harvests in green (the red line is a modelled result).37

The Commission’s latest proposal on LULUCF, if adopted in its existing form, would be a significant

improvement on the current rules. And rigorous LULUCF accounting is clearly a fundamental underpinning to

global efforts to tackle climate change and is essential for a wide variety of different purposes. But even if the

Commission’s proposals were adopted unchanged – something that seems unlikely given the fierce opposition to

it from Member States such as Finland that want to increase harvesting of forests for bioenergy and other

purposes without recording that fact in their accounts – it cannot ensure that bioenergy used in the EU delivers

genuine carbon savings over fossil fuels and is not therefore a solution to the problem of bioenergy sustainability.

This is for a number of reasons:

37

Graph reproduced from European Commission LULUCF impact assessment 2016 (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52016SC0249).

The rules on forest management fail to take adequately into account the question of what harvested wood is

used for. To take a hypothetical example, if effective policies by Member States led to a 50% reduction in

paper use (which would be a good thing from a climate perspective) all of the trees not used for paper

production could simply be burned for energy instead, without that even registering in the LULUCF

accounts. This would make no sense in climate terms, for the reasons set out in the main paper, but from a

LULUCF perspective would be acceptable. This is an example of a broader point, which is that:

LULUCF is an (extremely important) accounting and reporting system, but not at present a policy driver38.

The Commission has proposed that there be a ‘no-debit rule’ for the LULUCF sector, but this would not

provide an incentive in the LULUCF sector equivalent to the carbon targets in the sectors covered by the

Effort Sharing Regulation. Policy measures are therefore needed outside of the LULUCF sector (in

agriculture, transport, industry etc.) to ensure that the right action to reduce emissions actually happens.

Under LULUCF rules, for example, the use of agricultural land for purpose grown biofuel crops would create

no debit and so have no carbon ‘cost’, despite that practice being sub-optimal from a climate perspective (see

main paper).

Under the Commission’s LULUCF proposals for forest management, Member States would be allowed to take

account of the age class structure of their forests, which in many cases are still relatively young. This means

that higher harvests of wood will be possible in future, without that counting as a debit, simply because more

trees are expected to be, from a forestry perspective, ‘ready to harvest’. Decisions on harvesting may be

perfectly rational and economic but are not relevant to a climate change policy or carbon accounting

perspective, where the issue at stake is the amount of carbon stored in forests.

The Commission’s proposed LULUCF rules (for forest management and other LULUCF sectors) will only

apply within the EU. Few countries have an effective system of carbon accounting in place and it is extremely

unlikely that all those countries currently exporting wood pellets to the EU or those that may wish to do so in

future will implement LULUCF accounting rules strict enough to ensure that there is no incentive to harvest

trees for export, in the form of wood pellets.

Theoretically, if it were possible to measure carbon stocks perfectly accurately, if LULUCF rules were applied

rigorously in every country in the world, and if the LULUCF sector were fully integrated with all other sectors and

– most importantly – subject to the same targets, such that there were no longer a perverse incentive on Member

States or any economic operator to harvest forest or crops for energy rather than reduce emissions elsewhere,

then LULUCF rules might be effective in ensuring that only genuinely low carbon types of bioenergy were used.

But none of these conditions is likely in the near future. And there are also very good reasons for keeping the

LULUCF sector separate, and subject to separate targets, namely:

Merging the sectors or allowing offsetting between them as the Commission has proposed could greatly

reduce the incentive to decarbonise ‘difficult’ sectors such as industry or agriculture. Indeed there would be a

strong incentive simply to maintain and extend forest carbon stocks, as the negative emissions thus

generated would (in the short term) likely be a cheaper way of meeting EU GHG targets than achieving

emissions reductions elsewhere – particularly given that EU forests are growing back after centuries of over-

harvesting and are therefore a major carbon sink (i.e. a source of carbon sequestration). Such ‘negative

emissions’ are vital, and should be strongly incentivised, but should only count towards targets if they are

additional to what would have happened anyway – and should not be pursued at the expense of emissions

reductions in other sectors. If that happened, then once the potential for reforestation and forest restoration

in the LULUCF sector were exhausted, sectors such as industry and agriculture could be faced with the task

of decarbonising at impossibly high rates.

Storage of carbon by forests and land is not permanent, or at least not in the same way that emissions

reductions in other sectors can be. For example changes in levels of forest carbon due to disease, fire or

human intervention are an ever present risk, and mean that storing carbon in forests cannot be treated in

exactly the same way as a permanent change in the energy efficiency of a building, or the dismantling of a

coal-fired power station and its replacement with a wind farm.

38

As the report for DG Energy by Matthews et al puts it: “Existing EU and international accounting systems for biogenic carbon in forests and harvested wood, supporting international efforts to limit GHG emissions, serve very specific purposes and are unsuitable for more general application as calculation methods for assessing the GHG emissions associated with forest bioenergy” (https://ec.europa.eu/energy/sites/ener/files/2014_biomass_forest_research_report_.pdf)

For all the reasons above, LULUCF accounting in the land use sector is not a solution to the problem of high

carbon bioenergy, something that can only be addressed through effective sustainability criteria within bioenergy

policy. The IPCC itself recognises that “the IPCC approach of not including these emissions in the Energy Sector

total should not be interpreted as a conclusion about the sustainability or carbon neutrality of bioenergy”39.

39

http://www.ipcc-nggip.iges.or.jp/faq/faq.html, question Q2.10.

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For further information: Alex Mason Senior Policy Officer,

Renewable Energy,

WWF European Policy

Office

Email: amason@wwf.eu

Mobile +32494762763

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